We present an analysis of the relative bias between early- and late-type galaxies in the Two-degree Field Galaxy Redshift Survey (2dFGRS) – as defined by the η parameter of Madgwick et al., which quantifies the spectral type of galaxies in the survey. We calculate counts in cells for flux-limited samples of early- and late-type galaxies, using approximately cubical cells with sides ranging from 7 to 42 h−1 Mpc . We measure the variance of the counts in cells using the method of Efstathiou et al., which we find requires a correction for a finite volume effect equivalent to the integral constraint bias of the autocorrelation function. Using a maximum-likelihood technique we fit lognormal models to the one-point density distribution, and develop methods of dealing with biases in the recovered variances resulting from this technique. We then examine the joint density distribution function, f(δE, δL) , and directly fit deterministic bias models to the joint counts in cells. We measure a linear relative bias of ≈1.3, which does not vary significantly with ℓ. A deterministic linear bias model is, however, a poor approximation to the data, especially on small scales (ℓ≤ 28 h−1 Mpc) where deterministic linear bias is excluded at high significance. A power-law bias model with index b1≈ 0.75 is a significantly better fit to the data on all scales, although linear bias becomes consistent with the data for ℓ≳ 40 h−1 Mpc .